ML20029D235

LER 94-006-00:on 940330,discovered That Braidwood Cooling Lake Hydrographic Survey Was Not Completed within Required Time.Cause Was Personnel Error.Corrective Action: Surveillance Was Completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.W/940429 Ltr

ML20029D235
Person / Time
Site:	Braidwood
Issue date:	04/29/1994
From:	Kofron K, Tidmore J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BW-94-0070, BW-94-70, LER-94-006-01, LER-94-6-1, NUDOCS 9405040245
Download: ML20029D235 (5)

Text

l 1

Os Csnuntnw: lth Edissn Braidwood Nuclear Power Statior, l

• /

1^21 ) Route #1, Box 84 i

[ i

\ A/ Braceville, lliinois 60407 Telephone 815/458-2801 l

April 29, 1994 i

BW/94-0070 l

U.S. Nuclear Regulatory Commission I Document Control Desk i Washington, D.C. 20555

Dear Sir:

l The enclosed Licensee Event Report from Braidwood Generating Station is being transmitted in accordance with the requirement of 10CFR50.73 (a) (2) (i) (B), which requires a 30-day written report.

This report is number 94-006-00, Docket No. 50-456.

[

K. L. Kofhn Station Manager l Braidwood Station Encl: Licensee Event Report No. 456/94-006-00 cc: NRC Region III Administrator NRC Resident Inspector INPO Record Center CECO Distribution List i

I 1

l l

1 030100 f$0"$85$Eos888!s6 gaV' PDR } !

l I

b- -

l l

~

==-

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 3150-0104 (5<92) EXPIRES 5/31/95 ESilMATED BURDEN FER RESPONSE TO COMPLY WITH

" ^ LL LICENSEE EVENT REPORT (LER) IoOARD N REGARDING BURDEN SI TE b THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, (See reverse for required number of digits / characters for each block) N, C 20555 0001 AND TO THE RWO MANAGEMENT AND BUDGET, WASHINGTON. DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) PAGE (3)

Braidwood 1 05000456 1OF4 l TITLE (4) I Missed Technical Specification Surveillance Due to Personnet Error and Progranmatic Deficiencies )

EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

SE TIAL REV N FACILITY NAME DOCKET NUMBERS MONTH DAY YEAR YEAR MONTH DAY YEAR Braidwood 2 05000457 CKET EMBER 03 30 94 94 -- 006 -- 00 04 29 94 ELnY NAME OPERATING g THIS REP M IS WBMMHD PURWANT TO THE REWIREMEHS OF 10 UR D ( W ck one or mon) (M)

MODE (9) 20.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71(b)

''''' ' '''' S '73'* "' #3'#''

POWER LEVEL (10) 000 20.405(a)(1)(li) 50.36(c)(2) 50.73(a)(2)(vii) OTHER 20.405(a)(1)(iii) X 50.73(a)(2)(i) 50.73(a)(2)(viii)(A) (Specify in ,

Ab trac tow 20.405(a)(1)(iv) 50.73(a)(2)(ii) 50.73(a)(2)(viii)(B) 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x) NRC Form 366A) j LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (include Area Code) ,

J. Tidmore, System Engineering (815)458-2801 x2299 l COMPLETE ONE LINE FOR EA'.H COMPONENT F AILURE DESCRIBED IN THIS REPORT (13)

CAUSE SYSTEM COMPONENT MANUFACTURER L

CAUSE SYSTEM COMPONENT MANUFACTURER

^L 0 S 0 P DS l

SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED YES SUBMISSION x No (If yes, complete EXPECTED SUBMISSION DATE). DATE (15)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

At 1415 on 03/30/94, it was discovered that the Braidwood Cooling Lake l Hydrographic Survey, an 18-month surveillance to verify the depth of the l Essential Service Cooling Pond (ESCP), was not completed within the l

required time. The root cause of the event was a personnel error. The System Engineer stated that it was his understanding that the Surveillance must be started prior to the due date and completed as soon as possible.

Also, windy conditions which are typical during the fall / winter make performance of the Surveillance difficult because wave action causes erratic bottom readings. A contributory cause was a programmatic deficiency. The document used to track surveillances was updated with the start date and this was interpreted as a compietion acknowl Mgement. The Surveillance was completed within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance period extension allowed in the Technical Specifications. It is planned to have all surveillance packages reviewed and filed with surveillance tracking personnel. There have been previous occurrences of missed Technical Specification Surveillances associated with personnel errors NRC FORM 366 (5-92)

l NRC FORM 366A U.S. NUCLEAR REGULATORT COMMISSIONI APPROVED BY OMB NO. 3150-0104 (5<92) EXPlRES 5/31/95 ESilMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

i LICENSEE EVENT REPORT (LER) $!"#"r0$1N N A I ^[fCo[DS MA AGE B AN (MNBB 7714), U.S. NUCLEAR REGULATORY COMMIS$10N, TEX"' CONTINUATION WASHINGTON, DC 20555 0001 AND TO THE PAPERWORK I REDUCTION PROJECT (31$00104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON. DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

Braidwood 1 SEQUEM I AL RE W ON YEAR 05000456 NUMBER NUMBER 2OF4 94 -- 006 -- 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

A. PLANT CONDITIONS PRIOR TO EVENT:

Unit: Braidwood 1; Event Date: March 30, 1994-Event Time: 1415; Mode: 6; Rn Power: 0005; i RCS [AB) Temperature / Pressure: 62 degrees F / 12 psig; 1

Unit: Braidwood 2; Event Date: March 30, 1994; i Event Time: 1415;

( Mode: 1; Rn Power: 100%;

i RCS [AB] Temperature / Pressure: NOT/NOP l

B. DESCRIPTION OF EVENT:

l At 1415 on 03/30/94, it was discovered that periodic surveillance BwVS 7.5.2-1, Braidwood Cooling Lake Hydrographic Survey, had not been completed within the allowable surveillance time. The surveillance was last successfully completed on 04/06/92. This resulted in the new due date of 10/08/93 with an allowable completion date (critical date) of 02/22/94 utilizing the approved 251 surveillance entension period.

The surveillance was started on 10/7/93, but was not completed within the allowed frequency time. The System Engineer believed that the surveillance 1 must be started by the due date, but did not understand that it must be '

completed by the critical date of 2/22/94.

The Surveillance Tracking System (GSRV) did not recognize the incomplete surveillance because the GSRV tracking document was updated to show a starting date of 10/7/93. This was taken as a completion acknowledgement by the clerk entering the data in GSRV. The surveillance was, therefore, shown as completed on 10/7/93 in the GSRV tracking.

The surveillance requires the System Engineer (non-licensed) to take depth readings of the Essential Service Cooling Pond (ESCP) at 100 ft. intervals, .

over the entire ESCP, using a depth finder with a chart recorder. Windy l conditions made performance of the surveillance difficult because it is i difficult to maintain the boat's course across the ESCP. The wave action also causes erratic bottom readings which are very difficult to interpret '

in the charts.

This event is being reported pursuant to 10CFR50.73 (a) (2) (i) (B) - any operation or condition prohibited by the plant's Technical Specifications. I l

1 I

I

. _ _ _ . .~ , _ _ _ . - _ _ _ - _

4 I

NRC FORM 366 (5 92)

NRC FORM 366A U.S. NUCLEAR REGULATORT COMMISSION APPROVED BY OMB NO. 3150-0104 (5-92) EXP!RES 5/31/95 ESilMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO 4 LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION,

TEXT CONTINUATION WASHINGTON, DC 20555 0001 AND TO THE PAPERWORK REDUCTION PROJECT (31$00104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

Braidwood 1 yggg SEQUENTIAL REVISION NfJMBER NUMBER 05000456 3 of 4 4

94 -- 006 -- 00

} TEXT (if more space is required, use additional copies of NRC Form 366A) (17)

C. CAUSE OF THE EVENT

, The root cause of the event was a personnel error. The System Engineer

stated that it was his understanding that the Surveillance must be started i prior to the due date. The System Engineer did not realize that the surveillance had to be completed prior to the critical date. Also, this was aggravated by the existing weather conditions during the fall and i winter.

A contributory cause was a programmatic deficiency. The Surveillance Tracking System (GSRV) did not recognize the incomplete surveillance i because the GSRV tracking document was updated to show a starting date of 10/7/93, and this was taken as a completion acknowledgement.

D. SAFETY ANALYSIS:

This event had no effect on plant or public safety. The Hydrographic Survey is performed to verify the depth of the Essential Service Cooling Pond. The minimum depth ensures enough cooling water is available to safely shutdown the plant in the event of dike failure. The ESCP is still

. deep enough to remain operable and has not measurably changed depth since the initial performance.

i E.

CORRECTIVE ACTIONS:

l The surveillance was completed within the 24-hour surveillance period

extension allowed in Technical Specification 4.0.3. At 1500 on March 30, i 1994, the System Engineer began completion of the surveillance. The i

surveillance was completed on March 31, 1994 at 1225. The average elevation of the ESCP bottom was 583.26 ft. which is well below the 584 ft.

minimum elevation required by Tech Specs.

i h

4

- - . ~ . . n-

r NRC FORM 366 (5 92)

N3C FORM 366A U.S. NUCLEAR REGULATORY LOMMISSION APPROVED BY OMB No. 3150 0104 (5 92) ,

EXPIRES 5/31/95 EST! MATED BURDEN PER RESPONSE TO COMPLY WITH l THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. I

" " "^

l LICENSEE EVENT REPORT (LER) $I^iOr0fM$ A$'#[C00DS M NAGE BRAN TEXT CONTINUATION (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001 AND TO THE PAPERWORK REDUCTION PRO. LECT (31'IO 0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

l FACltlTY NAME (1) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

Braidwood 1 SEQUENTIAL REVISION j YEAR 05000456 NUMBER NUMBER 4 OF 4 94 -- 006 -- 00 TEXT (if more space is required, use additional copies of NRC Form 366A) (17)

The surveillance packages for Operations and Fuel Handling are now being i reviewed and filed with the surveillance tracking personnet. Also, the i surveillance packages currently processed by System Engineering are being l reviewed and filed with the surveillance tracking personnel. This will eliminate the potential for interpreting a start date for a comp 1ation date. It is planned to have all surveillance packages reviewed and filed with the surveillance tracking personnel. This action will be tracked to completion by action item 456-180-94-00601.

l F. PREVIOUS OCCURRENCES

• i l l There have been previous . :currences of missed Technical Specification l Surveillances associated with personnel errors associated with the GSRV process. This does not constitute an adverse trend in that the events involved different systems and methods of discovery.

LER NO. TITLE:

50-456/s -005 LER l-93-005; MISSED TECHNICAL SPECIFICATION SURVEILLANCE l

50-457/93-004 LER 2-93-004; CORE REACTIVITY NORMALIZATION SURVEILLANCE FOR UNIT 2 CYCLE 4 NOT PERFORMED IN REC)UIRED TIME FPId4E i

! 50-457/93-005 LER 2-93-005; MISSED SURVEILLANCE ON CONTAINMENT  :

ISOLATION VALVE l

G. COMPONENT FAILURE DATA:

This event was not the result of component failure, nor did any components fail as a result of this event.

{

l l

l .==m.

_